California, United States of America
The following excerpt is from People v. Joiner, D064432 (Cal. App. 2014):
Even if we were to conclude that Joiner did not waive his assumed constitutional right to be personally present during the remand hearing, and thus that the court erred in conducting that hearing in his absence, we would nevertheless conclude that any such error was harmless beyond a reasonable doubt under the standard of Chapman v. California (1967) 386 U.S. 18, 24. (See People v. Fisher (2009) 172 Cal.App.4th 1006,
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